Georgia Tax Residency: 183 Days, Foreign Income and Remote Work

Separate personal tax residence, Georgian-source income and treaty relief. A guide for international residents, remote employees and freelancers with income connected to more than one country.

Four questions to answer separately

For Georgia, the country, establish your tax residence for the relevant year, classify each income stream and its source, check the applicable regime or exemption, and identify filing obligations. A residence permit, rented home, bank account or IE registration does not itself establish personal tax residence.
This guide concerns individuals. A company’s residence and a business permanent establishment need separate analysis. Georgian residence also does not prove that obligations in another country have ended.

183 days in a continuous 12-month window

Article 34(2) treats an individual as resident for the entire current tax year if the individual has actually stayed in Georgia for at least 183 days in any continuous 12-calendar-month period ending in that tax year. The window is continuous; your visits do not have to be.
This is not just a January-to-December travel count or a rule that residence starts on day 184. The whole-year wording must still be read separately from income-source rules, exemptions and any applicable treaty.
Under Article 34(8), status is established for each tax period, and days used to establish residence for a previous tax period are not reused for following periods. Keep the previous year’s calculation when working across a year end.
Simple example: 100 countable days plus another 83 countable days inside one qualifying window make 183. Leaving between visits does not reset the count. This example assumes no statutory exclusions or days already used for the preceding period.

Count days using the statutory exceptions

Article 34(5) counts a day regardless of how much of that day was spent in Georgia. Arrival and departure days can therefore count, subject to exceptions; count one calendar day once.
Article 34(3) also includes time abroad specifically for treatment, leisure, a business trip or education. Article 34(4) excludes specified diplomatic, international-organisation and foreign-public-service stays, transit between foreign countries, and stays in Georgia for treatment or leisure.
Do not assume every absence is excluded or every visa-free visit is excluded as tourism. The purpose and facts of the stay need evidence. Keep border-crossing dates, travel purposes, accommodation and work documents, and obtain an RS review where the result turns on disputed days.

Other residence routes are conditional

Article 34(2) also covers Georgian public service abroad. Paragraphs 6, 6¹ and 6² address special cases, including high-net-worth individuals, a Georgian citizen whose residence cannot be established elsewhere, and specified cases for foreign individuals.
These provisions do not give every foreigner a residence route simply by registering an IE, buying property or opening a bank account. Confirm the applicable ministerial procedure and current eligibility with RS. This guide does not assert unverified asset thresholds or a guaranteed application route.

Georgian-source income is not the payment location

Article 104 includes employment exercised in Georgia (104(1)(a)) and services actually performed in Georgia (104(1)(c.a)). A foreign employer, client, currency or payment platform does not by itself make that income foreign-source.
Article 104(1)(c.g) also addresses services between parties in different countries where the supplier is Georgian-resident, with an exception for delivery through the supplier’s permanent establishment in another country confirming performance there. Working while travelling abroad does not automatically establish foreign-source income.
Article 104(2) says the place where money is received is not taken into account in determining source. Interest, dividends, royalties, rent and asset sales have their own source provisions. Split mixed contracts into their actual components.

The foreign-source income exemption

Article 100(1) includes both Georgian and foreign-source income in a resident’s gross income. Article 82(1)(u) exempts a resident individual’s income, including gains, that is not Georgian-source. Read these together with Article 104: determine residence, then income type and source, then the exemption.
An overseas transfer is not an exemption category. Work performed in Georgia for a foreign client can be Georgian-source. For foreign bank interest or rent, check the specific payer, establishment and property rules instead of borrowing the services test.
This is a personal income-tax exemption. It does not decide a company’s tax position, property tax, all reporting obligations or another country’s rules. Keep documents supporting each classification.

Remote work: three common situations

Employee working from Georgia for a foreign employer: assess employment exercised in Georgia and the employment article of any applicable treaty. Holding IE or SBS status does not turn salary into 1% business income; Article 90(3) excludes salary from the SBS base.
Independent contractor working from Tbilisi for an overseas business: actual performance in Georgia is a source criterion under Article 104(1)(c.a). Review the contract, SBS eligibility and VAT separately. The client being foreign does not settle any of those questions.
Work in several countries with salary, business fees and investments: list each income type, work location and period separately. Apply Article 104, including the resident cross-border service rule, and the relevant treaty before combining figures in a return.

Less than 183 days does not mean no tax

Article 79 includes a non-resident individual receiving Georgian-source income among income-tax payers. Article 80 distinguishes income connected with a permanent establishment, other income and certain property transactions; Article 134 covers withholding in specified cases.
Do not wait for your 183rd day to assess local work income. Source, legal classification and treaty eligibility determine the next questions about payment, withholding and filing. This guide does not assign a universal non-resident rate.

Two countries and treaty relief

Under Article 2(7), a ratified tax treaty in force takes priority over the Code. Verify that a treaty exists and applies to the countries, person, taxes, income and period involved. Do not assume that moving to Georgia terminates your former residence or all foreign reporting.
If both countries treat you as resident, check the particular treaty’s residence tie-breaker. Then check the article for the income itself and the prescribed exemption or credit mechanism. Residence and employment provisions may use different tests; a 183-day reference in an employment article is not a substitute for Article 34.
Use the actual treaty and retain the certificates and tax-payment evidence it requires. A Georgian certificate is not a guarantee of relief, and any foreign tax cannot automatically be deducted from SBS. Conflicting residence or disputed treaty eligibility needs individual review.

Certificate of Residence

Use the Revenue Service Certificate of Residence route linked below to confirm the current application process. Establishing residence for a year and calculating tax on a particular income stream are different tasks. An IE extract or SBS certificate does not replace residence evidence.
As a preparation checklist, gather identification and tax number, the year requested, travel-day calculations and the legal basis, the other country and the purpose of the certificate. This is not an exhaustive official document list; confirm the current form and attachments with RS.
Retain contracts, work-location evidence, residence certificates for the relevant periods and evidence of withholding and tax paid. The certificate alone does not resolve dual residence or guarantee a foreign refund.

Connect the result to IE, SBS, VAT and filing

Tax residence does not grant SBS or prove eligibility for 1%. Article 90(3) ties the SBS base to Georgian-source income and excludes salary and specified items.
VAT place of supply under Article 162¹ is different from income source under Article 104. A correctly classified service can be outside Georgian VAT territory while producing Georgian-source income for income tax. Confirm both tests rather than carrying the answer from one to the other.
Article 153 governs annual income-tax filing in specified cases, including resident income not taxed at source in Georgia. Review exemptions and income-specific duties separately. An SBS return, residence certificate or absence of VAT is not proof that no other return is required.

Your pre-filing checklist

Fix the tax year, travel dates and previously used days. Resolve special-purpose stays before relying on the day count.
Split salary, independent services, rent and investments. For each, record the Article 104 source basis and the documents supporting any Article 82 exemption.
Check the other country and applicable treaty, then IE/SBS, VAT and reporting separately. Give RS or your adviser the calculation and contracts for disputed days, special residence routes or mixed cross-border income.
Reviewed on 3 September 2026 against the current Matsne Tax Code, publication 245 (25 June 2026), and RS Certificate of Residence route. Verify the rules applicable to your income period before filing.

Tax Residency in Georgia: the 183-Day Rule and Income from Foreign Clients

Four questions to answer separately

183 days in a continuous 12-month window

Count days using the statutory exceptions

Other residence routes are conditional

Georgian-source income is not the payment location

The foreign-source income exemption

Remote work: three common situations

Less than 183 days does not mean no tax

Two countries and treaty relief

Certificate of Residence

Connect the result to IE, SBS, VAT and filing

Your pre-filing checklist

Official verification

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